SOLAR ELECTRIC PERMIT FEES IN SOUTHERN CALIFORNIA

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1 SOLAR ELECTRIC PERMIT FEES IN SOUTHERN CALIFORNIA A COMPARATIVE REPORT By Carl Mills, Kurt Newick, Jim Stewart and Tamara Winter Compeán copyright 6/21/09 Version 1.4 Contents 1 Executive Summary Survey Parameters Geographic Scope Customers Survey Period Survey Questions Survey Highlights Lowest Fees Highest Fees Shortest Processing Times Longest Processing Times Solar Friendly Municipalities Worst Practices The Benefits of Solar Permitting Issues Health and Safety Unnecessary Requirements Load-bearing Considerations Wind-bearing Considerations Fire Department Reviews Planning Department Reviews Public Works Department Reviews Homeowners Association (HOA) Reviews Inspector Training Permit Fee Assessment...9 Solar Electric Permit Fees in Southern California Page 1 of 49

2 Published 6/21/09 Sierra Club Flat-fee vs. Valuation-based Method Calculating a Flat Fee for Cost Recovery Solar Laws Laws that Promote PV Energy Laws Governing PV Permits and Fees Survey Results Permit Fees Composite Ranking Charts: a Measure of Overall Solar Friendliness Time-to-issuance Ranking Criteria Definitions for Time-to-issuance Terms Composite Ranking Formula Composite Ranking Charts Recommendations Conclusion References Contacts Download or View the Report Online More Information About Permit Fee Results by County Average Permit Fees for All Counties Los Angeles County Ventura County Orange County Santa Barbara County Riverside County San Bernardino County Imperial County Kern County San Luis Obispo County San Diego County Endnotes Executive Summary In early 2009, several Sierra Club chapters surveyed 250 municipalities in Southern California to determine their fees and processing times for the permits to install photovoltaic (PV) energy systems (solar panels) on residential rooftops. The survey found that fees for a typical PV system varied from $0 to over $1,500. The goal of this report is to publicize the role those municipal governments play in helping, or hindering, homeowners who want to contribute to California's supply of renewable solar energy. Page 2 of 49 Solar Electric Permit Fees in Southern California

3 2 Survey Parameters 2.1 Geographic Scope The survey included all the municipalities in the following counties (with the corresponding Sierra Club chapter in parentheses): Imperial (San Diego) Kern (Kern-Kaweah) Los Angeles (Angeles) Orange (Angeles) Riverside (San Gorgonio) San Bernardino (San Gorgonio) San Diego (San Diego) San Luis Obispo (Santa Lucia) Santa Barbara (Los Padres) Ventura (Los Padres) 2.2 Customers Only residential single-family homeowners (commercial installations are NOT included). 2.3 Survey Period February 1 to April 13, Note that the data in this document are frequently updated to reflect our awareness of changes and corrections to the fees that the municipalities originally reported. 2.4 Survey Questions The survey team asked each municipality the same questions, as follows: Permit fee "What is the total 1 cost for a permit to install a 3kW solar electric system on a composite-shingle roof of a single-story residence in your jurisdiction (assuming the system cost is $27,000 before the California Solar Initiative i [CSI] rebate)? The system will be professionally installed and mounted flush to the roof. It will have 1 inverter and 20 solar modules. It will be 320 square feet in size and have a weight load of 3 pounds per square foot. Fee calculation "Is the fee primarily based on valuation (system costs) or a fixed cost, independent of system cost? Permit processing time "Are solar electric permits issued over the counter? If not, how many days typically elapse between permit submittal and issuance?" 1 Total here means the combined cost for all the various fees and reviews (e.g. electrical review, plan check, issuance fee, fees charged by other city departments (such as planning and fire), required state fees, etc.) Solar Electric Permit Fees in Southern California Page 3 of 49

4 Published 6/21/09 Sierra Club Some cities charge higher fees for installations that require more staff time and resources from the permitting authority. Therefore, the survey team provided the following specifications when conducting the survey to equalize the comparisons across jurisdictions: All equipment is Underwriter's Laboratory (UL) approved. 2 DC source circuits of 10 panels wired in series (assume wire sizing is up to code). Professionally engineered solar mounting system. Assume professional installation by a California licensed solar contractor (C46 license category). 1 A/C disconnect (not fused). Existing 125 amp electrical subpanel is used with 1 new 20-amp circuit breaker to connect inverter output to the household electrical system. The PV system is connected to the utility s electric grid (grid-tied) with no batteries or charge controllers. The California Energy Commission (CEC) has certified the solar equipment and it is eligible for the CSI rebate. Assume a full set of plans for the permit submittal package, including a wiring schematic and site plan (showing the roof, solar modules and locations of the inverter and main electrical meter). Assume wire sizing and other electrical calculations are shown. The plans for the inverter, solar modules and solar mounting system include specification sheets of the equipment being installed. Building that will support the solar panels is built to modern building codes, can structurally support the extra 3 pounds per square foot of weight, and rafters are not over-spanned. 3 Survey Highlights The survey revealed huge disparities in how different local governments have helped or hindered residents who want to install PV systems. In measuring how solar friendly municipalities are, we use the following criteria: Permit fee: The average PV permit fee in the survey area is $493. We recommend a maximum of $ Processing time: Most jurisdictions took 1 2 weeks to issue a PV permit. We encourage over-the-counter 3 (OTC) issuance for standard PV applications that are complete and contain no errors. We recommend a maximum time-to-issuance of one week or less. The following subsections list some of the best, and worst, survey findings. (See Section 6 Survey Results for the complete findings.) 3.1 Lowest Fees 21 municipalities offer free PV permits. 104 municipalities charge $324 or less. 2 See Section Calculating a Flat Fee for Cost Recovery for an explanation of how we determined this recommended maximum. 3 OTC issuance means the PV applicant receives the permit during his or her initial visit to the building department. Page 4 of 49 Solar Electric Permit Fees in Southern California

5 3.2 Highest Fees 70 municipalities charge $700 or more for PV permits. 3.3 Shortest Processing Times 41 municipalities consistently issue PV permits over-the-counter (OTC) Longest Processing Times 34 municipalities consistently take over two weeks (10 business days) to issue PV permits. 3.5 Solar Friendly Municipalities The following municipalities stand out as among the most solar friendly, as they issue PV permits over-the-counter (OTC) and waive permit fees. Burbank City of San Bernardino San Clemente 5 San Diego County Ventura County Besides these five municipalities, many others meet our definition of solar friendly in that they offer OTC issuance and charge fees no higher than our recommended maximum ($324). See Section 6 "Survey Results" for complete rankings of all the surveyed municipalities. 3.6 Worst Practices The following permit requirements contribute the most to exorbitant fees and long processing times in the survey's least solar-friendly municipalities. Valuation-based fees: The practice of basing a permit fee on the cost of a PV system contributes more to high fees than any other factor. Municipalities often apply valuationbased fees to various home improvement projects that require permits. However, this is unsuitable for PV systems due to their high material costs (relative to installation costs), which have no bearing on the staff-hours a municipality must devote to review PV systems of different sizes. Excessive solar permit fees such as those yielded when fees are calculated using the valuation method are disfavored and inconsistent with the California Solar Rights Act. For details, see Section "Laws Governing PV Permits and Fees." Fire department reviews: These can add unnecessary fees and up to two weeks to the processing time for a permit. Some fire department regulations can also severely restrict the placement of PV systems, reducing their power generation capacity. 4 The word "consistently" here distinguishes these 41 municipalities from others that issue OTC permits infrequently depending on various factors. See Section 6.2 for a complete discussion of this issue. 5 San Clemente initiated its fee waiver program on 8/12/2008. The program runs until 6/30/09, when the San Clemente City Council will review it. The council will decide whether or not to extend the program based on its success. Solar Electric Permit Fees in Southern California Page 5 of 49

6 Published 6/21/09 Sierra Club Public works department reviews: These can require homeowners to pay for such things as sidewalk replacement or tree maintenance before the building department can issue the PV permit. In at least one municipality, this review extended permit processing up to 15 days. Planning department reviews: Having a department other than the building department review PV plans for zoning issues (setbacks and height restrictions) can increase both the time and cost to process a PV permit. In some municipalities, the planning department also evaluates PV permit applications based on aesthetic considerations. Note that the California Solar Rights Act (California Government Code Section (b)) limits the review of solar energy systems by city building officials to whether they meet applicable health and safety requirements. Discretionary reviews, including a design review for aesthetics, are prohibited. Municipal utility approvals: Some municipalities that have their own electric utility add additional obstacles to obtaining a PV permit by requiring prior utility review and approval of paper work such as rebate/incentive forms and interconnection/net metering agreements before issuing PV permits. This can substantially delay permit issuance. 4 The Benefits of Solar As previously stated, the goal of this report is to publicize the role municipal government plays in helping, or hindering, the production of solar energy at the homeowner level. This goal is premised on the understanding that rooftop PV systems contribute a partial solution to a growing array of environmental, economic and national-security problems related to energy production. The following are some of the more obvious benefits homeowners provide to their municipalities, California, the United States and the Earth in general by installing PV systems. Generating PV electricity does not produce any of the greenhouse gasses (GHGs) that are responsible for global warming ii. In contrast, generating electricity via coal or natural gas produces massive amounts of GHGs. Solar energy currently provides just 0.2% of California's electricity. Coal provides 16.6% and natural gas provides 45.2%. iii California gets more sunshine hours than any state besides Arizona. iv As such, this state has a tremendous, unrealized potential for solar energy. PV electricity reduces our reliance on polluting energy sources such as natural gas. Natural gas emissions add tons of pollutants that cause smog and contribute to thousands of deaths and hospital visits in California every year. PV generates its maximum output during the day, and can help meet peak demand. This reduces the need for the most inefficient and most highly polluting power plants in the state. If current population trends continue, California s population will increase from 36 million in 2007 v to 59 million by 2050 vi. PV, together with energy efficiency and conservation, can reduce the number of new power plants that might otherwise be required to meet the future energy needs of California s growing population. Rooftop PV virtually eliminates long-distance electric transmission losses (which are around 7%) because the individual home can be both the source and destination of the energy. PV could provide a local source of electricity to help protect a community in time of earthquake or other emergency, when distant transmission lines and power plants might not be operating. Page 6 of 49 Solar Electric Permit Fees in Southern California

7 Once a PV system is installed, it takes advantage of the free energy of the sun, requires minimal maintenance, and can last at least 35 years. This makes PV an outstanding long-term financial investment for homeowners. 5 Permitting Issues Homeowners can install their own PV systems or hire solar contractors to install them. Regardless of who installs a system, the installer needs a municipal permit before installation can legally start. After installation, a municipal inspector must verify the PV system meets requirements. If it does, the inspector signs off the permit. The following entities require the permit: Municipalities: A city or county government (never both) must process and issue the PV permit. Municipalities pay their own staff or outside consultants 6 to review PV plans and inspect installations. Utilities: Electric utilities require a signed-off PV permit before officially authorizing a PV system s operation and connection to the electric grid. Solar rebate issuers: Entities that issue solar rebate money (e.g. the California Energy Commission and Southern California Edison) require a signed-off permit before issuing the rebate. Permit requirements for a PV system differ for each municipality. The following subsections describe the issues related to those requirements and their impact on permit fees and processing times. 5.1 Health and Safety Installing systems that generate electricity and connecting them to the transmission grid is potentially dangerous. Municipalities review permits applications to ensure PV system plans meet building and electrical code requirements. These requirements protect homeowners, contractors, firemen, transmission grid technicians and the grid itself from various dangers: Poor installations might cause electrocution or fires, and are vulnerable to power surges during blackouts. A safe backflow of power into the grid is important for the PV owner and the community that relies on the grid. The homeowner s roof must be able to support a PV system. The PV system s rack and roof attachments must be water tight and meet wind-load requirements. 5.2 Unnecessary Requirements Each city has its own set of pre-installation reviews for solar permits. The following subsections describe how some review criteria add unnecessary costs and time to the permitting process. 6 Municipalities that receive few PV applications tend to pay outside consultants, who often charge more than staff would. PV permit fees are often higher in such cases. Solar Electric Permit Fees in Southern California Page 7 of 49

8 Published 6/21/09 Sierra Club Load-bearing Considerations The flush-mounted PV systems that most homeowners install have a low-enough weight/area ratio that they cannot overload standard roofs. Such PV systems should not require professional engineering stamps unless the site has unique structural issues that the installer must address Wind-bearing Considerations Flush-mounted PV systems should not require professional engineering stamps for wind loading unless the site is in an excessive wind zone: wind zone category D, with basic wind speeds of 80 miles per hour or greater, as defined by the California Building Code Fire Department Reviews Some municipalities require a fire department review of the PV system plan to verify it meets requirements for: Marking: PV equipment labels provide emergency responders (e.g. firemen) with appropriate warning and guidance for working around and isolating the PV system. Access: Emergency responders require pathways to specific areas of the roof and emergency egress from the roof. Ventilation: Proper roof ventilation reduces the severity and effects of fire and smoke, facilitates fire fighting procedures and reduces dangers to the inhabitants. Fire department reviews as they currently exist tend to make PV permits more expensive and extend their processing time for the following reasons: A fire department is often in a different location than a municipality s building department, which compels the solar applicant to make two trips. Some fire departments impose a guideline that PV modules be located no higher than three feet below the roof ridge. Shading issues are such that the highest parts of a roof are usually optimal for module placement; the lower the modules are, the more likely they are to fall under the shadows of trees, telephone poles and other obstructions. Thus, this guideline diminishes both the surface area available for modules and their power generation capacity. We recommend that municipalities adopt the following measures: Train building department staff to verify that PV systems meet fire department requirements. This would reduce permit processing time by negating the need for the solar applicant to make trips to multiple locations. Reconsider imposing the guideline limiting PV modules to three feet below the roof ridge. Alternative access and venting on adjacent roof surfaces are almost always available. As such, negotiating the setback on a case-by-case basis makes more sense than strictly applying the three-foot rule to all PV systems. Some fire departments have realized this and have adopted more flexible, less restrictive setbacks Planning Department Reviews A municipality s planning department is separate from its building department and might review PV systems for such issues as height restrictions, setbacks and zoning. Requiring multiple departments to review a single PV system increases both the time and cost to process a PV permit. Moreover, standard PV systems that are flush-mounted to a roof typically do not violate Page 8 of 49 Solar Electric Permit Fees in Southern California

9 height restrictions. We recommend that municipalities train their building department staff to verify that PV systems meet planning department requirements. In some municipalities, the planning department also evaluates PV systems based on aesthetic considerations. Note that the California Solar Rights Act (California Government Code Section (b)) limits the review of solar energy systems by city building officials to whether they meet applicable health and safety requirements. Discretionary reviews, including a design review for aesthetics, are prohibited Public Works Department Reviews Some municipalities require a public works department review for PV permits. Such reviews involve a municipal employee inspecting the public right of ways on the property whose owner is applying for the permit. Right of ways can include sidewalks, aprons, curbs, gutters and city street trees. If the conditions of those right of ways do not meet municipal standards (e.g. sidewalks have cracks), the municipality can charge the homeowner for the cost to upgrade the right of ways. Such reviews always increase the processing time for PV permits and can also increase their costs. We recommend that municipalities remove such review requirements for PV permits as they have no bearing on health and safety issues relating to actual PV systems (as required by Code Section (b) mentioned above) Homeowners Association (HOA) Reviews Some municipalities require that homeowners obtain HOA approval to install a PV system as a condition to issue the permit. This extends the permit processing time. Moreover, some HOAs charge review fees for such approvals. We recommend that municipalities require homeowners to merely notify their HOA of their intention to install a PV system to enable prompt, over-thecounter permit issuance, as HOA reviews can take several weeks. 5.3 Inspector Training Inspectors who review PV systems on-site after installation usually charge cities by the hour for their services. Cities pass on those charges to the solar installer, and ultimately to the customer. Therefore, a fast inspector is a less expensive inspector. To be fast and thorough, an inspector must be knowledgeable about PV systems. An inspector's expertise is a critical factor controlling both the permit cost and safety of a solar installation. Various organizations sponsor workshops for solar inspectors, including solar contractors/manufacturers, building departments, and the International Association of Electrical Inspectors (IAEI) (see Section 9.3 for more information). 5.4 Permit Fee Assessment Flat-fee vs. Valuation-based Method Cities typically compute residential solar permit fees using a flat-fee method, a valuation-based method, or a combination of these methods. The flat-fee method applies the same fee regardless of system cost. The valuation method usually bases fees on the pre-rebate cost of a PV system: the more solar panels one purchases, the higher the fee. A consequence of the valuation method is that the more a homeowner contributes to a city s renewable energy supply, the more that homeowner must sacrifice financially when applying for a permit. Solar Electric Permit Fees in Southern California Page 9 of 49

10 Published 6/21/09 Sierra Club Compared to other home improvement projects, material costs for PV systems are high relative to installation costs. However, those material costs have no bearing on the resources a city must devote to review PV systems of different sizes. According to John Cheng, the Chief Building Official of the City of Burbank, "In general, it costs the same amount of money to process a residential system regardless of the size. Generally, the systems are submitted with manufacturer specifications so there is no difference." Calculating a Flat Fee for Cost Recovery We estimate a permit fee of $324 would recover a municipality s costs to review and inspect a residential PV system. This recommended maximum assumes: A standard PV system as described in Section 2 A professional permit application with no errors An inspector trained in PV installations A billable rate of $108/hour for staff-hours (this varies among municipalities) One hour for the plan check One hour for the inspection One hour for miscellaneous permit processing tasks Based on these assumptions, $108/hour x 3 staff-hours = $ Solar Laws Laws that Promote PV Energy State law SB 107 vii accelerates California s renewable portfolio standard and requires investor owned utilities to achieve a 20 percent renewable electricity portfolio by the end of California s Million Solar Roofs Initiative viii (SB 1) requires home developers to offer PV as an option starting January 1, This legislation created 10 years of incentives, starting in 2007, with a goal to install the equivalent of 1 million 3kW solar electric systems in California. California law compels cities to exempt PV systems when assessing a home's value for property taxes for homeowners who retrofit solar power on their current home (California Revenue and Taxation Code Section 73). ix AB 920 x, currently being considered by the California legislature, would if passed, require utilities to pay their customers for the solar energy that they produce and do not use for their own home Laws Governing PV Permits and Fees California Government Code Section provides that fees associated with building inspections and building permits "shall not exceed the estimated reasonable cost of providing the service for which the fee is charged." (Emphasis added). The California Solar Rights Act xi limits the review of solar energy systems by city building officials to whether they meet applicable health and safety requirements. (See California Government Code Section (b) and California Health and Safety Code Section Page 10 of 49 Solar Electric Permit Fees in Southern California

11 ) Discretionary reviews, including a design review for aesthetics, are prohibited. Section (a) states: It is the intent of the Legislature that local agencies not adopt ordinances that create unreasonable barriers to the installation of solar energy systems, including, but not limited to, design review for aesthetic purposes. For details on this issue, see the letter of intent about solar permit fees that State Senator Lois Wolk authored. The letter, which was ed to all California Cities on June 7, 2006, can be found at: 6 Survey Results 6.1 Permit Fees In order to determine the total fees a city charged to review and approve a permit for a residential solar PV installation, our survey team members gathered information via phone, or fax from permit technicians and building officials. Our surveyors also gathered information from city planners, fire department personnel, other city staff as well as staff from companies and agencies that provide contract services to municipalities. The following tables show the total fees from all sources in each municipality surveyed 7. The fees were quoted for a PV system with the specifications described in Section 2 "Survey Parameters." The tables list the municipalities by fee (highest to lowest) and alphabetically (so you can find your own municipality). The average fee for the survey area appears in the bottom row. To see the fee rankings for a particular county, see Section 9.4 "Permit Fee Results by County." Ranked by Fee Ranked Alphabetically Municipality Total Fee Municipality Total Fee La Habra Heights $1,572 Adelanto $180 Rolling Hills $1,479 Agoura Hills $1,058 San Gabriel $1,479 Alhambra $213 Carson $1,473 Aliso Viejo $924 Hawaiian Gardens $1,427 Anaheim $0 Westlake Village $1,389 Apple Valley $316 Whittier $1,328 Arcadia $283 Pismo Beach $1,305 Arroyo Grande $350 Lawndale $1,214 Artesia $1,030 Azusa $1,197 Arvin $308 Lomita $1,183 Atascadero $273 Rolling Hills Estates $1,168 Avalon $792 Bell $1,166 Azusa $1,197 Downey $1,164 Bakersfield $136 Irwindale $1,156 Baldwin Park $432 Los Angeles County $1,144 Ballard $293 Huntington Park $1,100 Banning $236 7 These fees do not reflect the business license fee required by most municipalities for all firms doing business in that city. Business licenses are usually $30 to $200 and are valid for a year. Solar Electric Permit Fees in Southern California Page 11 of 49

12 Published 6/21/09 Sierra Club Ranked by Fee Ranked Alphabetically Municipality Total Fee Municipality Total Fee Paramount $1,082 Barstow $250 Cerritos $1,078 Beaumont $416 West Hollywood $1,077 Bell $1,166 Inglewood $1,066 Bell Gardens $450 Agoura Hills $1,058 Bellflower $925 Artesia $1,030 Beverly Hills $350 Dana Point $1,020 Big Bear Lake $415 El Monte $1,014 Blythe $54 Torrance $1,009 Bradbury $306 La Mirada $1,008 Brawley $200 San Dimas $1,000 Brea $466 Placentia $983 Buellton $293 Needles $973 Buena Park $242 Industry $967 Burbank $0 Duarte $965 Calabasas $658 Ontario $954 Calexico $709 Coachella $954 California City $681 Norwalk $945 Calimesa $655 Hawthorne $943 Camarillo $430 Los Alamitos $942 Canyon Lake $683 Bellflower $925 Carlsbad $120 Aliso Viejo $924 Carpinteria $245 Compton $900 Carson $1,473 Oxnard $900 Casmalia $293 Newport Beach $900 Cathedral City $211 Santa Fe Springs $895 Cerritos $1,078 San Marino $891 Chino $665 Montebello $852 Chino Hills $514 South Gate $822 Chula Vista $45 West Covina $815 Claremont $435 South El Monte $814 Coachella $954 Rancho Santa Margarita $807 Colton $683 Glendora $805 Commerce $675 Lakewood $800 Compton $900 Maywood $798 Corona $660 Avalon $792 Coronado $268 Fullerton $791 Costa Mesa $0 Pico Rivera $785 Covina $645 Lompoc $763 Cudahy $717 Malibu $761 Culver City $0 Perris $754 Cuyama $293 Indio $738 Cypress $625 Page 12 of 49 Solar Electric Permit Fees in Southern California

13 Ranked by Fee Ranked Alphabetically Municipality Total Fee Municipality Total Fee Imperial County $737 Dana Point $1,020 Walnut $735 Del Mar $190 Lake Elsinore $735 Delano $65 Orange $717 Desert Hot Springs $660 Cudahy $717 Diamond Bar $704 Calexico $709 Downey $1,164 Santa Maria $706 Duarte $965 Diamond Bar $704 El Cajon $225 Ridgecrest $702 El Centro $478 Grover Beach $702 El Monte $1,014 Laguna Niguel $700 El Segundo $515 Tustin $695 Encinitas $388 Gardena $692 Escondido $102 Vernon $687 Fillmore $155 Canyon Lake $683 Fontana $0 Colton $683 Fountain Valley $663 California City $681 Fullerton $791 Commerce $675 Garden Grove $160 Morro Bay $675 Gardena $692 Chino $665 Glendale $0 Fountain Valley $663 Glendora $805 Desert Hot Springs $660 Goleta $174 Corona $660 Grand Terrace $452 Calabasas $658 Grover Beach $702 Calimesa $655 Guadalupe $415 Paso Robles $653 Hawaiian Gardens $1,427 Hermosa Beach $650 Hawthorne $943 Covina $645 Hemet $473 Laguna Woods $633 Hermosa Beach $650 Moorpark $628 Hesperia $296 Temple City $625 Hidden Hills $225 Cypress $625 Highland $472 Yorba Linda $614 Hope Ranch $293 Temecula $604 Huntington Beach $0 Long Beach $599 Huntington Park $1,100 National City $595 Imperial Beach $95 Rancho Cucamonga $591 Imperial County $737 San Fernando $582 Indian Wells $0 Solvang $554 Indio $738 San Jacinto $530 Industry $967 McFarland $524 Inglewood $1,066 Monrovia $520 Irvine $210 Solar Electric Permit Fees in Southern California Page 13 of 49

14 Published 6/21/09 Sierra Club Ranked by Fee Ranked Alphabetically Municipality Total Fee Municipality Total Fee Sierra Madre $515 Irwindale $1,156 El Segundo $515 Isla Vista $293 Chino Hills $514 Kern County $225 Victorville $513 Kern County wildland area $360 Pomona $510 La Canada Flintridge $356 El Centro $478 La Habra $410 Hemet $473 La Habra Heights $1,572 Highland $472 La Mesa $156 Brea $466 La Mirada $1,008 San Luis Obispo County $462 La Palma $211 Oceanside $455 La Puente $131 Grand Terrace $452 La Quinta $337 Bell Gardens $450 La Verne $331 Upland $450 Laguna Beach $0 Montclair $445 Laguna Hills $183 Yucaipa $441 Laguna Niguel $700 Claremont $435 Laguna Woods $633 Baldwin Park $432 Lake Elsinore $735 Camarillo $430 Lake Forest $254 Santa Barbara $430 Lakewood $800 Signal Hill $419 Lancaster $58 Beaumont $416 Lawndale $1,214 Big Bear Lake $415 Lemon Grove $274 Guadalupe $415 Loma Linda $0 Thousand Oaks $411 Lomita $1,183 La Habra $410 Lompoc $763 Rancho Palos Verdes $402 Long Beach $599 Westminster $400 Los Alamitos $942 Stanton $398 Los Alamos $293 Monterey Park $395 Los Angeles $308 Yucca Valley $391 Los Angeles County $1,144 Encinitas $388 Los Olivos $293 Norco $375 Lynwood $350 Palm Springs $375 Malibu $761 Kern County wildland area $360 Manhattan Beach $0 Seal Beach $359 Maywood $798 La Canada Flintridge $356 McFarland $524 Arroyo Grande $350 Menifee $220 Beverly Hills $350 Mission Viejo $0 Lynwood $350 Monrovia $520 San Juan Capistrano $350 Montclair $445 La Quinta $337 Montebello $852 Page 14 of 49 Solar Electric Permit Fees in Southern California

15 Ranked by Fee Ranked Alphabetically Municipality Total Fee Municipality Total Fee La Verne $331 Montecito $293 Palmdale $330 Monterey Park $395 Simi Valley $327 Moorpark $628 Ojai $325 Moreno Valley $155 Apple Valley $316 Morro Bay $675 Arvin $308 Murrieta $257 Los Angeles $308 National City $595 Bradbury $306 Needles $973 Santa Clarita $300 Newport Beach $900 Hesperia $296 Norco $375 Vista $295 Norwalk $945 Ballard $293 Oceanside $455 Buellton $293 Ojai $325 Casmalia $293 Ontario $954 Cuyama $293 Orange $717 Hope Ranch $293 Orange County $16 Isla Vista $293 Orcutt $293 Los Alamos $293 Oxnard $900 Los Olivos $293 Palm Desert $0 Montecito $293 Palm Springs $375 Orcutt $293 Palmdale $330 Santa Barbara County $293 Palos Verdes Estates $85 Santa Ynez $293 Paramount $1,082 Summerland $293 Pasadena $198 Vandenberg Village $293 Paso Robles $653 Ventucopa $293 Perris $754 Twentynine Palms $290 Pico Rivera $785 Arcadia $283 Pismo Beach $1,305 Lemon Grove $274 Placentia $983 Atascadero $273 Pomona $510 Santa Paula $270 Port Hueneme $100 Coronado $268 Poway $131 Murrieta $257 Rancho Cucamonga $591 Lake Forest $254 Rancho Mirage $194 Barstow $250 Rancho Palos Verdes $402 Carpinteria $245 Rancho Santa Margarita $807 Buena Park $242 Redlands $110 Banning $236 Redondo Beach $202 El Cajon $225 Rialto $0 Kern County $225 Ridgecrest $702 Villa Park $225 Riverside $210 Hidden Hills $225 Riverside County $215 Solar Electric Permit Fees in Southern California Page 15 of 49

16 Published 6/21/09 Sierra Club Ranked by Fee Ranked Alphabetically Municipality Total Fee Municipality Total Fee Menifee $220 Rolling Hills $1,479 Riverside County $215 Rolling Hills Estates $1,168 Wildomar $215 Rosemead $122 Alhambra $213 San Bernardino County $0 Cathedral City $211 San Bernardino (City) $0 La Palma $211 San Clemente $0 Irvine $210 San Diego $93 Riverside $210 San Diego County $0 Santee $206 San Dimas $1,000 Redondo Beach $202 San Fernando $582 Brawley $200 San Gabriel $1,479 Pasadena $198 San Jacinto $530 Rancho Mirage $194 San Juan Capistrano $350 Del Mar $190 San Luis Obispo $40 Solana Beach $190 San Luis Obispo County $462 Laguna Hills $183 San Marcos $100 Adelanto $180 San Marino $891 Goleta $174 Santa Ana $0 Garden Grove $160 Santa Barbara $430 La Mesa $156 Santa Barbara County $293 Fillmore $155 Santa Clarita $300 Moreno Valley $155 Santa Fe Springs $895 Ventura $150 Santa Maria $706 Bakersfield $136 Santa Monica $0 La Puente $131 Santa Paula $270 Poway $131 Santa Ynez $293 Rosemead $122 Santee $206 Carlsbad $120 Seal Beach $359 Wasco $112 Shafter $102 Redlands $110 Sierra Madre $515 Escondido $102 Signal Hill $419 Shafter $102 Simi Valley $327 Port Hueneme $100 Solana Beach $190 San Marcos $100 Solvang $554 Imperial Beach $95 South El Monte $814 San Diego $93 South Gate $822 South Pasadena $88 South Pasadena $88 Palos Verdes Estates $85 Stanton $398 Delano $65 Summerland $293 Lancaster $58 Tehachapi $53 Blythe $54 Temecula $604 Tehachapi $53 Temple City $625 Page 16 of 49 Solar Electric Permit Fees in Southern California

17 Ranked by Fee Ranked Alphabetically Municipality Total Fee Municipality Total Fee Chula Vista $45 Thousand Oaks $411 San Luis Obispo $40 Torrance $1,009 Orange County $16 Tustin $695 Anaheim $0 Twentynine Palms $290 Burbank $0 Upland $450 Costa Mesa $0 Vandenberg Village $293 Culver City $0 Ventucopa $293 Fontana $0 Ventura $150 Glendale $0 Ventura County $0 Huntington Beach $0 Vernon $687 Indian Wells $0 Victorville $513 Laguna Beach $0 Villa Park $225 Loma Linda $0 Vista $295 Manhattan Beach $0 Walnut $735 Mission Viejo $0 Wasco $112 Palm Desert $0 West Covina $815 Rialto $0 West Hollywood $1,077 San Bernardino (City) $0 Westlake Village $1,389 San Bernardino County $0 Westminster $400 San Clemente $0 Whittier $1,328 San Diego County $0 Wildomar $215 Santa Ana $0 Yorba Linda $614 Santa Monica $0 Yucaipa $441 Ventura County $0 Yucca Valley $391 Average $493 Average $ Composite Ranking Charts: a Measure of Overall Solar Friendliness The charts in this section express as a single value or composite rank the impact that fees and policies related to permit issuance have on solar customers in each municipality. To rank solar friendliness, the charts quantify the municipalities fees and time-to-issuance for residential PV permits. While ranking municipalities by their permit fees is simple, it is equally important (though more complicated) to rank municipalities according to how long they take to issue permits. Time-toissuance is important because it correlates directly with the personnel costs that both municipalities and solar contractors must spend so that a solar installation can move forward. In other words, "time is money" for all the parties involved including, ultimately, the solar customer. The following subsections explain how we determined the values for the composite ranking charts. The last subsection includes the charts themselves. Solar Electric Permit Fees in Southern California Page 17 of 49

18 Published 6/21/09 Sierra Club Time-to-issuance Ranking Criteria Ranking municipalities by time-to-issuance involves quantifying factors that can hasten or delay the permit process. We have applied the following criteria in determining time-to-issuance values: 1. The most solar friendly municipalities consistently issue permits for standard PV systems over-the-counter (OTC). We assigned municipalities that indicated a general practice of issuing OTC permits the best time-to-issuance value (zero). 2. In some municipalities, OTC issuance is possible under certain circumstance (e.g. by appointment, if personnel are not too busy, if certain personnel are in the office, etc.). When a permit is not issued over the counter, the solar applicant must return to the building department at a later date to receive the permit. Such jurisdictions also provided a time-toissuance estimate for permit approval, which applies when OTC permit issuance is not possible. To derive the time-to-issuance business days ( TTI Days ) for municipalities with a possibility of OTC issuance, we adjusted their average time or days to issue permits by the estimated likelihood of an OTC issuance. 3. Where a municipality normally offers OTC (zero days) PV permit issuance, we weighted this more favorably than where a municipality claimed OTC was possible in certain circumstances but was not the norm. 4. Besides permit approvals from the building department staff, some municipalities require prior approval from other departments (e.g. fire, planning, public works or municipal utilities) or even an entirely separate agency (e.g. agencies contracted for fire protection) before they can issue permits. We added the time to obtain such approvals to those municipalities' overall time-to-issuance estimate. 5. Many municipalities responded to the survey question regarding time-to-issuance with a time range. For the composite ranking chart, we use the average of the quoted time range. For example, if the quoted range is 1 2 weeks, the charts use 7.5 business days in the TTI Days column Some Los Angeles County Fire departments issue PV permits OTC if less than 50% of a roof section is covered by PV panels. Otherwise the permit is taken in and issued within 10 days (0 10 days is the range). We ve assumed the PV panels cover more than 50% of the roof surface, and used 10 days for FD review times, to abide by policy for these Fire departments. Note: When calculating the time-to-issuance of the solar permit, all respondents were instructed to assume the initial permit application was complete and without errors. Applications that are incomplete or have errors understandably require additional processing time. See Section 7 for a list of "Recommendations" to streamline the permitting process and reduce the number of applications that are incomplete or have errors. 8 1 Week (5 Business Days) + 2 Weeks (10 Business Days) = 15 Business Days. We divided by 2 to find the average time to issuance of 7.5 days. Page 18 of 49 Solar Electric Permit Fees in Southern California

19 6.2.2 Definitions for Time-to-issuance Terms Municipalities responded to the time-to-issuance question using various units and terminology (e.g. minutes, hours, days, a few days, weeks, etc.). For the composite ranking chart, we standardized these responses: 1. We used over-the-counter (OTC) permit issuance with a TTI assigned rank of zero days for PV permits issued in less than a day. 2. We calculated all times using business days. For example, an issuance time of one week is five business days. 3. We define a time estimate of a few days as 3.5 business days. 4. The TTI Claimed column reports the total time it took for all required reviews and approvals in all municipal departments and outside governmental agencies. Surveyors relied on respondents to provide complete information and have reported these additional required reviews to the best of our ability. 5. Where possible, the report charts use an estimate of actual time to issue permits and approvals. Where actual time was not available, we used an average of the standard timerange that department staff were instructed to quote for permit review, issuance and approvals. A few respondents were adamant that this report not list an over-the-counter turnaround as a possibility or that we use the maximum number of days generally quoted for permit review, approval and turn-around. 6. Where the building counter required additional approvals and reviews from planning, zoning, fire, public works, municipal utility departments, etc., prior to issuing a permit, surveyors attempted to ascertain these additional review times. Unless a city expressly indicated the building counter would not accept a permit application until these other departments or agencies had signed off on the permit application, it was assumed that all reviews could be conducted concurrently. Therefore except where noted, these extra department and/or agency permit reviews only add additional time (TTI Claimed) when they take longer than the building counter review. 7. Although in a few instances cities indicated that the building counter would not issue a permit without approval of a private Homeowners Association (HOA), the review time and fees associated with HOA solar permit reviews is outside the scope of this study and therefore not considered. 8. The following characters and abbreviations found in the composite chart are defined as: o Bldg : Building department o FD : Fire department o + : Times were added to the building department review time as permit reviews occur sequentially (one after the other) for these departments. o / : Extra time was not necessarily added to the building department review time as permit reviews can be processed concurrently between departments. Solar Electric Permit Fees in Southern California Page 19 of 49

20 Published 6/21/09 Sierra Club Composite Ranking Formula We used the following formula to calculate the composite rank (based on the combined fee plus time-to-issuance value) of each municipality: 1. Composite rank factor: Divide the maximum fee by the maximum time. Then divide the fee by this factor to make the fee and time values numerically equivalent: 44.9 (i.e., the maximum fee and TTI Days used to compute this are: $1,572 fee / 35 days = 44.9 composite rank factor). 2. Add the TTI number in days to the total fee divided by the composite rank factor to get the Composite Rank score. For example: Composite Rank formula: TTI Days + (Total Fee / composite rank factor) = Composite Rank For example: Composite rank factor = 44.9; TTI Days = 3; Total Fee = $300 Composite Rank computation example: 3 days + ($300 / 44.9) = 9.7 Composite Rank 3. Rank the municipalities by the composite score. A zero fee and zero time-to-issuance (OTC) are optimal Composite Ranking Charts The following charts grade each municipality in terms of how solar friendly it is. This is expressed as a composite rank that combines permit fees and processing times. The best possible rank is zero, for municipalities that waive permit fees and consistently provide OTC issuance. Higher ranks indicate cities with high fees, long permit processing times or both. Cities with lower scores generally had lower fees and/or shorter permit processing times than cities with higher ranks. The first chart lists the municipalities in the order of composite rank (from worst to best). The second chart lists the municipalities in alphabetical order. In both charts, the average rank appears in the bottom row Composite Chart in Order of Rank Municipality Total OTC Time-to-issuance (TTI ) Claimed TTI Composite Fee Days Rank La Mirada $1,008 N 6-8 weeks West Hollywood $1,077 N 4-6 weeks bldg / 0-10 days FD Azusa $1,197 N 1 week bldg / 21 days Utility / 0-10days FD Hawthorne $943 N 4-6 weeks La Habra Heights $1,572 N 2 weeks Torrance $1,009 N 3-5 weeks Hawaiian Gardens $1,427 N 10 days San Gabriel $1,479 N 7-10 days Coachella $954 N 1 Month Colton $683 N 4-6 weeks Huntington Park $1,100 N 2-4 weeks bldg / 10 days FD Pismo Beach $1,305 N 10 days Bell $1,166 N days bldg / 10 days FD Page 20 of 49 Solar Electric Permit Fees in Southern California

21 Municipality Total OTC Time-to-issuance (TTI ) Claimed TTI Composite Fee Days Rank Artesia $1,030 N 3 weeks Downey $1,164 N few days - 4 weeks Carson $1,473 Y 1 day bldg days FD Ontario $954 N 15 days Westlake Village $1,389 N 1-2 days bldg / 2-5 days FD Bellflower $925 N 15 days Los Angeles County $1,144 Y 2 hours bldg days FD Lakewood $800 N 3-4 weeks bldg / 10 days FD Paramount $1,082 N 10 days bldg / 10 days FD Cerritos $1,078 Y 2 weeks bldg / 10 days FD El Segundo $515 N 4-5 weeks bldg / 3 weeks FD Rolling Hills $1,479 Y 0 to 2 days bldg wks HOA not included Tustin $695 N 3-4 weeks San Dimas $1,000 N 10 days Paso Robles $653 N days Placentia $983 N 2 weeks Chino $665 Y OTC - 3 to 4 weeks / 7-10 days FD Norwalk $945 N 10 days Lawndale $1,214 Y 2 hours - 4 days bldg / 2-4 days FD Dana Point $1,020 N 1-2 weeks Compton $900 Y 1-3 weeks Santa Fe Springs $895 Y OTC bldg + 10 days FD San Marino $891 N 2 weeks Whittier $1,328 Y 0 days Lomita $1,183 Y 0 days bldg days FD Rolling Hills Estates $1,168 Y 0-2 hours bldg days FD Montebello $852 N 2 weeks Los Alamitos $942 N 1-2 weeks South Gate $822 Y 0-10 days bldg / 0-10 days FD Aliso Viejo $924 N 1-2 weeks Maywood $798 Y 1 hour bldg days FD Fullerton $791 N 2 weeks Bell Gardens $450 N 3-4 weeks bldg / 10 days FD Pico Rivera $785 N 2 weeks bldg / 10 days FD South El Monte $814 N 8-10 days Covina $645 N days Inglewood $1,066 Y OTC - few days bldg / 2-4 days FD West Covina $815 N 7-10 days Sierra Madre $515 N 2-4 weeks Lake Elsinore $735 N 2 weeks Agoura Hills $1,058 N 2-3 days Solar Electric Permit Fees in Southern California Page 21 of 49

22 Published 6/21/09 Sierra Club Municipality Total OTC Time-to-issuance (TTI ) Claimed TTI Composite Fee Days Rank Cudahy $717 N 10 days bldg / 10 days FD Irwindale $1,156 Y 2 hours bldg Diamond Bar $704 N 10 days bldg / 0-10 days FD Needles $973 N 3-5 Days Rancho Cucamonga $591 N 2.5 weeks Vernon $687 N 2 weeks Canyon Lake $683 N 2 weeks Commerce $675 N 1-3 weeks bldg / 10 days FD Industry $967 Y 0 days bldg days FD Santa Ana $0 N 3 weeks (bldg & FD) / 5 weeks planning Fountain Valley $663 N 2 weeks Baldwin Park $432 N 0-2 days bldg/ 1-2 wks plan days FD Duarte $965 Y several days Temecula $604 N days Laguna Woods $633 N 2 weeks Oxnard $900 N 3-5 days Temple City $625 Y 2 hours bldg + 10 days FD Walnut $735 N 1-2 weeks bldg / (no FD review normal) Yorba Linda $614 N 2 weeks El Monte $1,014 Y 0-5 days (OTC on Mon. or Thur.) Santa Maria $706 N 1-2 weeks California City $681 N 1-15 days Laguna Niguel $700 N 1-2 weeks Glendora $805 N 1 week bldg Montclair $445 N 2-3 weeks Desert Hot Springs $660 N 1-2 weeks Corona $660 N < 2 weeks Hermosa Beach $650 N 1-2 weeks Malibu $761 Y 0 days bldg days FD Imperial County $737 N 1-10 days Signal Hill $419 N days Big Bear Lake $415 N 2-3 weeks Indio $738 N 1 week Lompoc $763 N 3-5 days National City $595 N 1-2 weeks Highland $472 N 2 weeks San Fernando $582 N 5-10 days Newport Beach $900 Y 0 days Twentynine Palms $290 N < 15 days Chino Hills $514 N 15 min days bldg / 7-10 days FD Escondido $102 N days Page 22 of 49 Solar Electric Permit Fees in Southern California

23 Municipality Total OTC Time-to-issuance (TTI ) Claimed TTI Composite Fee Days Rank Claremont $435 Y 0 days bldg days FD Avalon $792 N 2 days Calimesa $655 N 1 week Gardena $692 Y 0 days bldg days FD La Habra $410 N 1-2 weeks bldg / 10 days FD Upland $450 N < 2 weeks Goleta $174 N 2-4 weeks Perris $754 N 1-3 days Yucca Valley $391 N 10 days Encinitas $388 N 1 week bldg / OTC planning / 5-10 days FD Morro Bay $675 N 1-6 days San Luis Obispo County $462 N 1-15 days Rancho Santa Margarita $807 Y OTC - 5 days (OTC if complete submittal) Brea $466 N 1-2 weeks Lynwood $350 Y OTC bldg days FD Calexico $709 N 2 days Yucaipa $441 N < 10 days Cathedral City $211 N 2-3 weeks Ridgecrest $702 N 1-2 days Norco $375 Y OTC - 2 weeks (2 weeks normal) El Centro $478 N 2 days - 2 weeks Hesperia $296 N 10 days Orange $717 Y 0 days Grover Beach $702 Y 0 days Barstow $250 N 2 weeks Hemet $473 N 1 week Seal Beach $359 N 1-2 weeks Cypress $625 Y OTC - 4 days Monrovia $520 N 3-4 days Culver City $0 N 3 weeks Glendale $0 Y 0 days bldg + 3 weeks Glendale DWP Calabasas $658 Y 0 days Redondo Beach $202 N 2 weeks Solvang $554 N 1-3 days Bradbury $306 N 1-2 weeks Guadalupe $415 Y 1 week Ballard $293 N 1-2 weeks Buellton $293 N 1-2 weeks Casmalia $293 N 1-2 weeks Cuyama $293 N 1-2 weeks Hope Ranch $293 N 1-2 weeks Solar Electric Permit Fees in Southern California Page 23 of 49

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